NINTH DIVISION
[CA-G.R. SP No. 61436. July 7, 2006.]
FORT BONIFACIO DEVELOPMENT CORPORATION, petitioner, vs. COMMISSIONER OF INTERNAL REVENUE and REVENUE DISTRICT OFFICER, REVENUE DISTRICT NO. 44, TAGUIG & PATEROS, BUREAU OF INTERNAL REVENUE, respondents.
D E C I S I O N
AREVALO-ZENAROSA, M., J p:
Before Us is a petition 1 for review under Rule 43 of the Rules of Court seeking to reverse and set aside the Decision 2 dated October 12, 2000 of the Court of Tax Appeals (CTA) in CTA Case No. 5735, denying petitioner's claim for refund in the amount of Three Hundred Fifty-Nine Million Six Hundred Fifty-Two Thousand Nine Pesos and Forty-Seven Centavos (P359,652,009.47).
The facts of the case are as follow:
Petitioner Fort Bonifacio Development Corporationis a domestic corporation duly registered and existing under the Philippine laws. Petitioner is a duly registered VAT taxpayer. It is owned, to the extent of forty-five per cent (45%) of its issued and outstanding capital stock, by the Bases Conversion Development Authority, a wholly owned government corporation created by Republic Act (R.A.) No. 7227 3 for the...
